Applicant Privacy Policy

NOTE: The wording in this document reflects the requirements of the General Data Protection Regulation (GDPR).

Data Controller: “Ingram”

Scope:Any reference to Ingram shall refer to the applicable Ingram Content Group company which you are responding to an employment advertisement, including, without limiting, Ingram Content Group LLC, Ingram Book Group LLC, Ingram Publisher Services LLC, Book Network Int’l Limited, Lightning Source LLC, Lightning Source UK Ltd., Lightning Source Australia Pty Limited, and Lightning Source Germany GmbH.

As part of any recruitment process, Ingram collects and processes personal data relating to job applicants. Ingram is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Ingram collect?

Ingram collects a range of information about you. This includes:

Ingram collects this information in a variety of ways via different job recruitment platforms and agencies, Smart Recruiters (see Smart Recruiters privacy policy here), ICG Careers Portal, direct applications/ resumes, other online job portals – e.g., Linked In, Seek For example, data might be contained in, application forms, curriculum vitae (“CV”) or resumes, obtained from your passport or other government identification documents, or collected through interviews or other forms of assessment, including online tests (AVA).

Ingram will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and where relevant, information from criminal records checks. Ingram will seek information from third parties only once a job offer to you has been made and will make you that it is doing so.

Data will be stored in a range of different places, including paper personnel files, online files, within your application record, in internal human resources management systems and on other IT systems including email.

Why does Ingram process personal data?

Ingram needs to process data to take appropriate steps as part of the recruitment and job application process and at your request. It also needs to process your data to enter into a contract with you.

In some cases, Ingram needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work within the relevant country before employment starts.

Ingram has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Ingram to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Ingram may also need to process data from job applicants to respond to and defend against legal claims.

Where Ingram relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or job applicants.

Ingram may process health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligation and exercise specific rights in relation to employment.

Where Ingram processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes or by governmental requirement.

For some roles, it is appropriate and it many cases, legally required to seek information about criminal convictions and offences. Where Ingram seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

Ingram will not use your data for any purpose other than the recruitment purposes discussed in this policy.

If your application is unsuccessful, Ingram will keep your personal data on file in case there are future employment opportunities for which you may be suited. Ingram will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the human resources and recruitment teams, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary during the performance of their roles.

Ingram will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Ingram will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and other entities as necessary or required, including the Disclosure and Barring Service to obtain necessary criminal records checks.

Your data will be transferred outside the European Economic Area (EEA) internally to other ICG locations in the United States or externally to third parties for payroll or benefits reasons. Data is transferred outside the EEA on the basis of the model clauses for the transfer of personal data to processors established in third countries approved by the European Commission, the approved version of which is set out in the European Commission's Decision 2010/87/EU of 5 February 2010 and at

How does Ingram protect data?

Ingram takes the security of your data seriously and has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the collection of your personal information.   Ingram has internal policies and technical and controls in place for the purpose of ensuring your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees and those third party employees with a need to know in the performance of their duties.

For how long does Ingram keep data?

If your application for employment is unsuccessful, Ingram will hold your data on file for up to six months after the end of the relevant recruitment process.

If you agree to allow Ingram to keep your personal data on file, Ingram will hold your data on file for a further three years for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data will be deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you during your onboarding process in accordance with applicable privacy laws.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Ingram during the recruitment process. However, if you do not provide the information, Ingram may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Your rights

As a data subject, you have a number of rights. You can:

If you would like to exercise any of these rights, please contact

You can make a subject access request by completing Ingram’s form for making a subject access request which can be found here.

Ingram will respond in a timely manner.  In case of unresolved privacy or data use concern, You have the right to lodge a complaint with Your data protection supervisory authority.